In this second part of our year-in-review series, Elliot Berman and John Byrne examine the major developments from July to December 2025. From Treasury’s delay of the investment advisor rule and the adoption of the GENIUS Act to the staggering $2 billion in crypto theft, the conversation covers critical shifts in financial crime prevention. They discuss staffing cuts at the State Department, EU fintech risk assessments, FATF’s new national risk assessment toolkit, and the humanitarian toll of sanctions. Other highlights include AMLA’s growing role in EU crypto oversight, AUSTRAC’s crackdown on casino compliance, and global enforcement trends. Plus, insights on OCC’s testimony signaling regulatory priorities for 2026 and FATF’s report on combating online child exploitation. Stay informed as we close out a turbulent year in compliance.
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In this second part of our year-in-review series, Elliot Berman and John Byrne examine the major developments from July to December 2025. From Treasury’s delay of the investment advisor rule and the adoption of the GENIUS Act to the staggering $2 billion in crypto theft, the conversation covers critical shifts in financial crime prevention. They discuss staffing cuts at the State Department, EU fintech risk assessments, FATF’s new national risk assessment toolkit, and the humanitarian toll of sanctions. Other highlights include AMLA’s growing role in EU crypto oversight, AUSTRAC’s crackdown on casino compliance, and global enforcement trends. Plus, insights on OCC’s testimony signaling regulatory priorities for 2026 and FATF’s report on combating online child exploitation. Stay informed as we close out a turbulent year in compliance.
Navigating the AML Crossroads: 2025 in Review and What's Next
AML Conversations
32 minutes 13 seconds
2 weeks ago
Navigating the AML Crossroads: 2025 in Review and What's Next
In this candid year-end conversation, John Byrne and Sarah Beth Felix dissect an unprecedented year in AML enforcement. Felix, President of Palmero Consulting and creator of "Dirty Money Weekly," describes what she sees as systematic dismantling of AML infrastructure despite stated priorities of combating fentanyl and transnational criminal organizations. With only four enforcement actions from traditional federal banking agencies compared to FINRA's 20+ penalties, the landscape has shifted dramatically.
The discussion explores Treasury's proposal to give FinCEN veto authority over banking agency BSA decisions - a move Felix warns could create massive bottlenecks. They examine troubling patterns in recent OFAC sanctions penalties where entities disregard guidance while violations flow through traditional banks. Felix shares skepticism about AI replacing the "hyper suspicious" human judgment essential to AML work, noting AI tools consistently fail basic sanctions questions.
The conversation addresses the stark gap between U.S. and European cryptocurrency regulation, with America applying 40-year-old money service business laws to digital assets while the EU has comprehensive frameworks like MiCA. Looking ahead to 2026, Felix urges AML officers to use reduced regulatory scrutiny strategically - eliminating legacy policies that waste time while remembering everything missed now can trigger future enforcement. She emphasizes focusing on cartels and foreign terrorist organizations, which now carry criminal liability for banking officers, and proactively auditing customer sanctions programs.
AML Conversations
In this second part of our year-in-review series, Elliot Berman and John Byrne examine the major developments from July to December 2025. From Treasury’s delay of the investment advisor rule and the adoption of the GENIUS Act to the staggering $2 billion in crypto theft, the conversation covers critical shifts in financial crime prevention. They discuss staffing cuts at the State Department, EU fintech risk assessments, FATF’s new national risk assessment toolkit, and the humanitarian toll of sanctions. Other highlights include AMLA’s growing role in EU crypto oversight, AUSTRAC’s crackdown on casino compliance, and global enforcement trends. Plus, insights on OCC’s testimony signaling regulatory priorities for 2026 and FATF’s report on combating online child exploitation. Stay informed as we close out a turbulent year in compliance.
